https://www.taxtmi.com/caselaws?id=243433 The assessee failed to show, with material evidence, that Usha Sales was an independent branch rather than a permanent establishment under the India-Finland treaty. On the facts recorded, income attribution for the relevant contract work, including operations carried out in India, was treated as taxable in India because the assessee did not displace the revenue's case. The order also proceeded on the basis that the trailer-related work involved construction, assembly or installation operations in India. The departmental appeal was allowed, the CIT(A)'s order was set aside, and the assessment was restored. en-us Wed, 14 Aug 2013 00:00:00 +0530 Sat, 01 Feb 2014 17:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243433 The assessee failed to show, with material evidence, that Usha Sales was an independent branch rather than a permanent establishment under the India-Finland treaty. On the facts recorded, income attribution for the relevant contract work, including operations carried out in India, was treated as taxable in India because the assessee did not displace the revenue's case. The order also proceeded on the basis that the trailer-related work involved construction, assembly or installation operations in India. The departmental appeal was allowed, the CIT(A)'s order was set aside, and the assessment was restored. Case-Laws Income Tax Wed, 14 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243433